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Bureau of Energy and Technology Policy

June 29, 2018

Energy & Technology Committee Members

Connecticut General Assembly

210 Capitol Avenue

Hartford, CT 06106

Re: Shared Clean Energy Facilities Pilot Program Report to the Connecticut General Assembly

Dear Members of the Energy & Technology Committee:

The Department of Energy and Environmental Protection (“DEEP”) hereby submits this report to

the Connecticut General Assembly pursuant to Section 16-244x(f) of the Connecticut General

Statutes, which requires the following:

“On or before July 1, 2018, the department shall file a report, in accordance with

the provisions of section 11-4a, with the joint standing committee of the General

Assembly having cognizance of matters relating to energy, (1) analyzing the

success of the shared clean energy pilot program, (2) identifying and analyzing the

success of programs in other states that allow facilities similar to a shared clean

energy facility, and (3) recommending whether a permanent program should be

established in this state and, if so, any necessary legislation.”

On March 2, 2017, DEEP issued a Request for Proposals from private developers for shared clean

energy facilities. By Final Determination dated June 28, 2017, DEEP selected three projects to

participate in the Shared Clean Energy Facility Pilot Program in each electric distribution

company’s service territory:

Eversource Energy:

CHIP Fund 5 – Riverside Thompson 2.0MW, Thompson, CT

o Expected commercial operation date: June 30, 2018

Clean Energy Collective – Bloomfield Board of Education 1.62MW, Bloomfield, CT

o Expected commercial operation date: July 1, 2018

The United Illuminating Company:

US Solar Corp – USS Shelton 1.6MW, Shelton, CT

o Expected commercial operation date: September 30, 2019

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DEEP continues to monitor the progress in the development of the pilot projects while

simultaneously working on the implementation of a statewide shared clean energy program as

required by Public Act 18-50, An Act Concerning Connecticut’s Energy Future. Public Act 18-50 was

signed in to law on May 24, 2018. Section 7(c) of Public Act 18-50 directs DEEP to initiate a

proceeding, on or before September 1, 2018, to develop program requirements and tariff proposals to

establish a statewide shared clean energy program, and to submit, on or before July 1, 2019, any such

program requirements and tariff proposals to the Public Utilities Regulatory Authority for review and

approval. We look forward to providing additional updates to the Energy and Technology Committee

on DEEP’s progress in developing and implementing these programs.

Sincerely,

DEPARTMENT OF ENERGY AND ENVIRONMENTAL PROTECTION

Bureau of Energy and Technology Policy

Tracy R. Babbidge

Bureau Chief

Enclosure

Connecticut General Statutes §16-244x: Report to the Energy and Technology

Committee on the Shared Clean Energy Facilities Pilot Program

June 29, 2018

Connecticut Department of Energy and Environmental Protection

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Contents

I. Introduction .......................................................................................................................................... 1

II. Background .......................................................................................................................................... 1

III. Analysis of the SCEF Pilot Program .............................................................................................. 4

A. Power Purchase Pricing ................................................................................................................... 4

B. Economic Impact ............................................................................................................................. 4

C. Pilot Program Subscribership and LMI Minimum Subscription Requirement ............................ 5

D. Meaningful Commitment on the Part of Participating Subscribers .............................................. 7

E. Commercial Operation and Marketing Materials .......................................................................... 8

F. Generation Technology and Distribution System Impact.............................................................. 9

G. Environmental and Land Use Impacts from Siting ...................................................................... 10

H. Consumer Protections, Subscription Documents, and Billing Terminology .............................. 11

I. Reporting Requirements to DEEP after Commercial Operation Commences ........................... 14

J. Identification and Analysis of the Success of Similar Programs in Other States ....................... 14

IV. Conclusion ...................................................................................................................................... 16

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I. INTRODUCTION

The Department of Energy and Environmental Protection (“DEEP”) issues this report in accordance

with the provisions of Section 11-4a of the General Statutes of Connecticut, pursuant to Public Act

15-113, An Act Establishing a Shared Clean Energy Facility Pilot Program, as amended by

Public Act 16-116, An Act Concerning the Shared Clean Energy Facility Pilot Program (“the

SCEF Act”), as codified in Section 16-244x of the Connecticut General Statutes (“Conn. Gen.

Stat.”). The SCEF statute directs DEEP to file a report with the Energy and Technology

Committee of the General Assembly of Connecticut (“E&T Committee”) concerning the Shared

Clean Energy Facilities (“SCEF”) Pilot Program. Specifically, this report endeavors to provide:

Analysis of the SCEF Pilot Program; and

Identification and analysis of the success of similar programs in other states.

Conn. Gen. Stat. §16-244x(f) also directs DEEP to include in this report a recommendation on

whether a permanent program should be established in Connecticut and, if so, any necessary

legislation. However, two recent developments refocus the discussion and recommendations for this

report. First, DEEP released the 2018 Comprehensive Energy Strategy (“CES”) on February 8, 2018.

Among other key strategies, the CES recommends continuing to increase Connecticut’s level of

investment in renewables, while ensuring that investments optimize zero-carbon resource deployment

at the lowest cost to consumers, and address siting and land-use pressures through the development of

a working group. More pointedly, the CES identified SCEF program design challenges centered on

the fact that contracts between projects and the electric distribution companies (“EDCs”) are paid for

by all ratepayers but a credit is allocated only to participating customers. Thus, the CES recommends

addressing this issue in any statewide program rollout and integrating any statewide shared clean

energy program into successor programs supporting distributed generation.

Second, Public Act 18-50, An Act Concerning Connecticut’s Energy Future (“the Energy Future

Act”), was signed in to law on May 24, 2018. Section 7(c) of the Energy Future Act directs DEEP to

initiate a proceeding, on or before September 1, 2018, that develops program requirements and tariff

proposals to establish a statewide SCEF program, and to submit, on or before July 1, 2019, any such

program requirements and tariff proposals to the Public Utilities Regulatory Authority (“PURA”) for

review and approval.

Therefore, this report offers insight, commentary and recommendations as informed by DEEP’s

relatively brief experience with the pilot program, and spotlights certain noteworthy programs in other

states that are reflective of DEEP’s stance on relevant topics as articulated in the 2018 CES.

II. BACKGROUND

The SCEF Act requires DEEP to establish, in consultation with the EDCs, namely Eversource

Energy (“Eversource”) and The United Illuminating Company (“UI”), a two-year SCEF pilot

program using Class I renewable energy sources. Further, the SCEF Act directs DEEP to: (1)

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establish a billing credit for subscribers of a SCEF; (2) establish consumer protections for

subscribers and potential subscribers of such a facility; and (3) select, pursuant to a competitive

request for proposals (“RFP”) process, SCEF projects with an aggregate total nameplate capacity

rating of no more than six megawatts (“MW”), but no more than two MW in the aggregate in the

service territory of UI and no more than four MW in the aggregate in the service territory of

Eversource. Any tariff resulting from this pilot program is subject to review and approval by

PURA.

DEEP held an initial technical meeting on the pilot program on October 21, 2015. To clarify the

policy objectives of the pilot program, DEEP reviewed the findings, comments and testimony

submitted on SCEFs during prior legislative sessions. DEEP identified specific policy objectives

for the pilot program, including:

Expanding clean energy deployment;

Promoting equitable participation by increasing access to clean energy for low- to

moderate-income (“LMI”) customers;

Optimizing the positive re-use of sites with limited alternative uses; and

Supporting in-state economic development opportunities, and minimizing the cost to

electric ratepayers.

On May 20, 2016, DEEP released a draft RFP for public comment. DEEP held a public hearing

on the draft RFP on June 9, 2016, and accepted public comment on the draft RFP through June

20, 2016.

By way of a notice dated July 1, 2016, DEEP issued the Request for Proposals from Private

Developers for Shared Clean Energy Facilities (“Initial SCEF RFP”) to solicit proposals for the

SCEF pilot program by September 1, 2016. The Initial SCEF RFP allowed no more than three

pricing bids with each proposal. The Initial SCEF RFP also integrated the specific policy

objectives identified above to guide the evaluation and selection process. Further, on July 1,

2016, each EDC submitted a tariff that conforms to the requirements of the RFP to PURA for

approval. PURA subsequently approved such tariffs for Eversource and UI on July 7, 2016 and

August 18, 2016 respectively.

DEEP received nineteen project proposals from eight different developers in response to the

Initial SCEF RFP by the September 1, 2016 deadline. Four developers offered multiple pricing

options for their project proposals. Altogether, a total of twenty-nine pricing bids were

submitted. On February 1, 2017, DEEP issued a Final Determination (“Initial Final

Determination”) that declined to accept any bids submitted in response to the Initial SCEF RFP.

The Evaluation Team assigned by DEEP identified issues with four major components of the

Initial SCEF RFP that had the potential to adversely impact the pilot program’s operation and

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outcome, the participating and non-participating customers, and the EDCs. Concurrently, DEEP

released a revised draft RFP that addressed and modified those four components:

Siting restrictions to protect prime farmland, historic preservation properties, core

forests, and endangered, threatened and special concern species and significant

natural communities;

Limitation of commercial and industrial (“C&I”) customer subscription in the

aggregate to no more than 60 percent of the total production;

Elimination of the Subscriber Organization-managed credit and billing structure, as

presented in the Initial SCEF RFP; and

A pricing cap of $0.17 per kilowatt-hour (“kWh”).

DEEP received written and oral comments on its Initial Final Determination and revised draft

RFP. On March 2, 2017, DEEP released a final RFP (“SCEF RFP”) seeking bids through April

3, 2017, which was subsequently extended to April 10, 2017. On March 2, 2017, Eversource

submitted a tariff rider (“SCEF Rider”) that includes the terms and conditions of the pilot

program consistent with the SCEF RFP, which PURA approved effective April 1, 2017. On

March 6, 2017, UI submitted the SCEF Rider with the same terms and conditions. DEEP held a

bidders’ conference on March 16, 2017.

DEEP received nine project proposals from four developers in response to the SCEF RFP by the

April 10, 2017 deadline. One developer offered multiple pricing options for its two project

proposals. Altogether, a total of thirteen pricing bids were submitted. On June 28, 2017, DEEP

issued a Final Determination on the SCEF RFP (“Final Determination”) that selected the

following project proposals for the EDCs:

Eversource:

CHIP Fund 5 – Riverside Thompson 2.0MW, Thompson, CT (“CHIP Fund 5

Thompson SCEF”)

Clean Energy Collective – Bloomfield Board of Education 1.62MW, Bloomfield, CT

(“CEC Bloomfield SCEF”)

UI:

US Solar Corp – USS Shelton 1.6MW, Shelton, CT (“US Solar Shelton SCEF”)

The SCEF RFP defined “Bidder” as “an entity that submits a Proposal for a Subscriber Organization

and the development and operation of the SCEF consistent with the requirements of [the] RFP”.

“Subscriber organization” (“SO”) is defined by Conn. Gen. Stat. §16-244x(a)(5) as “any for-profit or

not-for-profit entity permitted by Connecticut law that (A) owns or operates one or more shared clean

energy facilities for the benefit of the subscribers, or (B) contracts with a third-party entity to build,

own or operate one or more shared clean energy facilities.” Relative to each of the three selected

project proposals, the bidder also functions as the SO.

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III. ANALYSIS OF THE SCEF PILOT PROGRAM A. Power Purchase Pricing

The SCEF RFP had set certain constraints on the purchase price to be offered by bidders for their

project proposals. Each project proposal was limited to no more than three purchase price bids not

exceeding the pricing cap of $0.17/kWh for each year of the tariff term. Moreover, a purchase price

could not be conditioned upon or subject to the availability of the Federal Production Tax Credit or the

Federal Investment Tax Credit, or the availability or receipt or continuation for any period of any other

tax treatment or government grant or subsidy.

All project proposals submitted in response to the SCEF RFP offered a flat price for the 20-year term

of service under the tariff. All purchase price bids were at or below the $0.17/kWh pricing cap. Two

project proposals offered three different pricing options for the same facility that allowed for different

credits to subscribers.

B. Economic Impact

DEEP performed a cost benefit analysis to compare the total expected cost of each SCEF project

against its total expected benefits. The annual direct costs for each selected project for its service term

were computed as the product of the total annual energy quantity and the forecast of the annual market

price per renewable energy certificate (“REC”).

Total expected benefits equate to the sum of the forecasted annual costs for energy and RECs.

Forecasted energy costs for each project are assumed to be the total market value of the energy

generated by the selected project in each year. These energy costs were calculated as the hourly

energy production (MWh) multiplied by the hourly energy price ($/MWh), summed over the year.

Forecasted REC costs are assumed to be the total market value of the RECs generated by the selected

project in each year. These REC costs were calculated as the annual energy production (MWh)

multiplied by the forecast of the annual market REC price ($/REC).

Total expected project costs are then compared with the sum of the forecasted costs of energy and

RECS to determine the net direct benefit and arrive at a Benefit to Direct Cost Ratio for each selected

SCEF project.

Selected

SCEF Project

Nominal Value

of Direct Cost

Nominal Value of

Direct Benefit

Net Direct

Benefit

Benefit to Direct

Cost Ratio

Shelton $8,806,818 $6,665,821 ($2,140,997) 0.757

Bloomfield $8,519,730 $6,403,444 ($2,116,286) 0.752

Riverside $11,297,477 $8,700,217 ($2,597,259) 0.770

All 3 Projects $28,624,024 $21,769,482 ($6,854,542) 0.760

The Benefit to Direct Cost Ratios for the selected SCEF projects are less favorable than in-state solar

projects recently selected in the Small-Scale Clean Energy RFP issued pursuant to Public Act 15-107,

An Act Concerning Affordable and Reliable Energy. Together, the three selected SCEF projects’

average cost is $0.165/kWh over the 20-year term of the contract in nominal dollars. This is higher

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than small grid scale projects selected in DEEP’s most recent procurement of Class I renewable

generation, which have an average cost of less than $0.10/kWh. The cost of the SCEF projects,

however, are less expensive than residential and commercial behind the meter roof top solar, which

DEEP estimates to cost over $0.20/kWh when the full cost of net metering and ratepayer incentives

are considered.

The higher costs under the SCEF pilot program may be attributable to higher acquisition costs and

greater financial risk. Under the pilot program, Subscriber Organizations need to attract prospective

customers and maintain a subscriber base that meets certain program provisions (i.e., minimum 20

percent subscription of SCEF output by LMI customers; commercial and industrial subscription

cannot exceed 60 percent of SCEF output). Moreover, developers must operate their SCEFs in

accordance with the EDCs’ tariffs. Payments or credits for energy and RECs produced by the SCEF

are sent from the EDC to the subscribing customer. That customer then sends payments to the

developer. This compares to grid-side projects that receive payments directly from the EDCs under

the terms and conditions of a purchase power agreement.

The SCEF projects have additional benefits that are not quantified in DEEP’s analysis of the direct

costs and benefits. Most importantly, these projects will provide access to solar for customers that

currently do not own a home or are otherwise not suited for rooftop solar. These renewable energy

projects will provide some economic development in local communities during their development and

may alleviate the need for some transmission and distribution investment by supplying power in

Connecticut. They also aid in suppressing wholesale energy and capacity prices, especially at times of

high electricity demand in the summer when renewable resources displace energy resources with

substantially higher operating costs.

C. Pilot Program Subscribership and LMI Minimum Subscription Requirement

Participation in the SCEF pilot program is open to residential, commercial, and industrial customers of

the EDCs. Each SCEF is required to have at least ten subscribers located within the same EDC

territory. Additionally, the Initial SCEF RFP imposed a subscription cap whereby a given customer

cannot have a subscription exceeding 40 percent of the SCEF’s estimated annual output.

To promote the policy objective of equitable participation, DEEP designed the pilot program to

specifically target residential LMI households. In both iterations of the RFP, bidders were required to

include a detailed method to obtain, and maintain for the life of its term, a subscriber base wherein a

minimum of 20 percent of the SCEF’s estimated annual output is utilized by subscribers that qualify

as LMI.

All project proposals submitted in response to the Initial SCEF RFP adequately met the minimum

LMI threshold requirement. However, DEEP observed that several proposals appeared to indicate a

preference by the bidders to subscribe SCEF output, beyond the 20 percent LMI requirement, to C&I

customers.

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Offering subscriptions largely to C&I customers is not detrimental to the SCEF pilot program. A

single C&I customer could more easily take on 40 percent of a SCEF’s output, as compared to

hundreds of residential customers. Nonetheless, an intent of the SCEF pilot program is to examine, on

a smaller scale, how a program that enables shared access to renewable energy to a broader range of

Connecticut’s residents – specifically renters and other residents whose homes are not appropriate

sites – would operate in the state. In its February 1, 2017 Final Determination, DEEP concluded that

such emphasis on C&I subscription would not align with the intent of broadening residential access to

renewable energy. Therefore, in the subsequent SCEF RFP, DEEP incorporated a modification

whereby no more than 60 percent of the estimated annual output of the SCEF is utilized by C&I

customers in the aggregate. For a fully subscribed SCEF, a minimum of 40 percent of its estimated

annual output must be subscribed to residential customers, of which 20 percent must specifically be

subscribed to residential customers or master-metered multi-unit building account holders who qualify

as LMI.

DEEP’s review of the nine program proposals submitted in response to the SCEF RFP concluded that

all proposals sufficiently met the program provisions for subscribership (i.e., minimum 20 percent

subscription of SCEF output by LMI customers; C&I subscription cannot exceed 60 percent of SCEF

output).

Under the pilot program, a residential customer would qualify as LMI if the gross annual income of

the customer’s household is eligible for any federal, state, or local assistance program that limits

participation to households whose income is at or below 175 percent of the federal poverty limit, or is

at or below 80 percent of the greater of (a) area median income, and (b) state median income, in either

case at the time of subscription. Moreover, in broadening access to clean energy to households

residing in master-metered multi-unit buildings, DEEP expanded LMI eligibility (for the purpose of

meeting the 20 percent LMI minimum subscription requirement) to include any capacity that is

subscribed to by the EDC account holder of a master-metered multi-unit building, wherein a tenant

would qualify under the above income guidelines.

Ideally, this extension encourages subscription by housing authorities and rental agencies that provide

housing to households meeting the LMI criteria but are not directly billed by an EDC. The downside

is that any direct financial benefit of a SCEF subscription involving a master-metered multi-unit

building would go to the landlord or owner of that building. Any financial benefit would not

necessarily extend to the tenants of that building, LMI or not, since the tenants are not the electricity

account holders, but pay for their electricity use as part of their rent payments or other payment

arrangement. Lastly, such a building is able to qualify toward the 20 percent LMI minimum

subscription requirement as long the SO obtains proof that at least one tenant meets the LMI criteria.

DEEP is interested in learning in the future to what extent master-metered multi-unit buildings

contribute to meeting the 20 percent LMI minimum subscription requirement, and how the SOs

qualify such buildings as LMI. As Connecticut moves toward implementing a statewide SCEF

program, DEEP recommends further contemplation of whether to continue to include, in some

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manner, participation by households that are not EDC account holders, and, if so, how to integrate

their participation more meaningfully.

DEEP reflected on the methods presented by the bidders for determining whether an EDC customer or

a master-metered multi-unit building meets the LMI criteria. Most of the bidders who responded to

either the Initial SCEF RFP or the SCEF RFP expressed plans to collaborate, partner, or consult with

one or more municipal groups (such as housing authorities, economic improvement boards, or clean

energy committees) and/or entities known to interact with LMI communities (such as Operation Fuel,

community service organizations, or other local causes), in order to develop outreach efforts to

identify potential subscribers that may meet LMI criteria. Another bidder indicated its intent to target

EDC households in nearby census tracts designated as low income using the most recent Housing and

Urban Development (“HUD”) data available. Yet another bidder planned to directly collaborate with

master-metered multi-unit building owners or agencies that provide housing to households meeting

the LMI criteria. DEEP is interested in learning about each SOs’ actual experience in administrating

their methods for LMI outreach and qualification. Such information, if timely received, might provide

some context and insight for consideration by DEEP to create incentives or other financing

mechanisms to encourage participation by low-income customers for the statewide SCEF program.

D. Meaningful Commitment on the Part of Participating Subscribers

DEEP’s evaluation of the project proposals received in response to the Initial SCEF RFP revealed that

none of the proposals required a financial investment from subscribers. Rather, each proposal

included a minimal one-time subscriber fee which ranged from $1 or less. Subscriber savings

ranged from 1.5 cents/kWh to 3.75 cents/kWh. DEEP concluded that the proposals generally did

not require the subscribers to have a meaningful interest or stake in the SCEF, either through

upfront costs or monthly subscription fees on participating customers that are not tied to the

actual output of the system. DEEP was concerned that none of the submitted project proposals

required a significant commitment or contribution by the subscribers for the billing credits they

will receive. Shared clean energy customers should be expected to have an interest in the clean

energy system, either by purchasing a portion of the clean energy facility through an upfront

payment or leasing arrangement tied to a portion of the facility, or making a commitment to

purchase the output from the facility over a period of time.

As a result, DEEP eliminated the SO-managed credit and payment structure entirely that was

offered in the Initial SCEF RFP. For the subsequent SCEF RFP, DEEP required bidders to adopt

the EDC-managed credit and payment structure, which was amended at that time to remove any

payment from the EDC to the SO except for the unsubscribed portion of generation, to more

closely mirror the residential rooftop solar programs.

A fundamental program design challenge remains, centering on the fact that contracts between

projects and the EDCs are paid for by all ratepayers but a credit is allocated only to participating

customers. To date, all contracts or tariffs with renewable generation, both grid-connected and

behind the meter, have been paid for by all ratepayers. For grid-connected projects, the financial

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benefits from those long-term contracts go to all ratepayers. For behind the meter projects, some

financial benefits go to all ratepayers, but many of the financial benefits accrue only to

participating ratepayers who own or lease rooftop solar systems. In the case of behind the meter

generation, host customers receive bill credits for their net generation, but put “skin in the game”

either by purchasing the solar system or by leasing through fixed monthly payments. In other

words, revenue from the sale of energy to the utility (as well as avoiding the need to purchase

grid-delivered energy) provides a return on their investment in solar panels. In addition to this

financial commitment, the project is sited on the customer’s home or property. Similarly, with

virtual net metering, the host has a financial interest through a purchase or lease, and the project

is sited on their property or a property in which they have an interest.

In contrast, proposals under the SCEF pilot program required no meaningful commitment on the

part of participating subscribers. None of the proposals received required the purchase or lease of

a portion of the system; rather, participating customers simply receive a credit from the EDC that

is paid for by all ratepayers and pass a portion of that along to the solar developer.

Allowing SCEF subscribers to receive a bill credit without putting “skin in the game” means that

credit is simply added to the price bid by the project proponent, locking all ratepayers into a

higher-priced contract than the market otherwise would accommodate. In the absence of

meaningful subscriber participation, DEEP could procure a unit of the same size through its grid

scale procurements at a lower price for all ratepayers. When community solar is offered to

subscribers without requiring any meaningful commitment or lease agreement from the

subscriber, the system is functioning the same as a grid scale installation but with an added cost

to non-participant ratepayers to pay for administering and delivering credits to subscribers who

have not provided any material support to the system. Credits to participating customers raise the

cost of the project, and this cost ultimately is borne by other ratepayers. Based on DEEP’s

experience with competitive solicitations, small grid-scale projects, similar in size to community

solar projects, can be developed in Connecticut more cost-effectively than through the shared

solar pilot structure and, in the process, provide the same benefits for all ratepayers, not just

subscribers.

E. Commercial Operation and Marketing Materials

To ensure the likelihood that each project proposal will become fully operational, DEEP evaluated the

extent of relevant experience a bidder has to successfully develop, finance, construct, operate, and

maintain a SCEF and successfully fulfill its responsibilities. To that end, the SCEF RFP required

bidders to detail the operational parameters of the energy resource plan, and the operation and

maintenance plans of their respective SCEF. Bidders needed to demonstrate that the technology it

proposes to use is technically viable. Moreover, bidders had to demonstrate the financial viability of

the proposed project, including the ability to fund development costs, the ability to post the required

development period security and operating period security, and the ability to acquire the required

equipment in the proposed time frame. All of the project proposals submitted in response to the SCEF

RFP adequately met these requirements.

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The SCEF RFP required bidders to be able to commit to a guaranteed in-service date for their

respective project proposals, whereby the SCEF must begin service: (1) after the date of PURA’s final

approval of the purchase price approved by DEEP through the RFP process; and (2) no later than July

1, 2020. Moreover, the timing of commercial operation was among the factors DEEP evaluated

qualitatively, in order to more quickly implement and learn from the pilot program.

The developers of the selected projects committed to the following commercial operation dates:

CHIP Fund 5 Thompson SCEF – June 30, 2018;

CEC Bloomfield SCEF – July 1, 2018; and

US Solar Shelton SCEF – September 30, 2019.

DEEP notes that the above in-service dates for the CHIP Fund 5 Thompson SCEF and the CEC

Bloomfield SCEF fairly coincide with July 1, 2018 filing date of the instant report to the E&T

Committee. Pursuant to Conn. Gen. Stat. §16-244x(e), the bidders for the three selected projects are

required to submit a status report on their respective SCEFs to the E&T Committee and DEEP no later

than one year after selection (which is June 28, 2018), and annually for two years thereafter. Via email

dated June 21, 2018, DEEP issued a reminder to each bidder about the required status report

submission. The RFP also provides for DEEP to obtain detailed reports from the selected bidders on

certain information (e.g., relevant subscriber information, LMI qualifications and subscribership,

implementation of terminations fees, etc.). However, the annual filing requirement for such reports do

not start for each SCEF until after commercial operation commences.

As of June 29, 2018, DEEP received status reports from CEC and US Solar, but not from CHIP Fund

5. CEC stated that its SCEF project will not be interconnected by July 1, 2018, but expressed

confidence that the project will be in-service within 12 months of that date. US Solar reported that it is

on track for its initial fall 2019 commercial operating date target. US Solar noted that it expects to

begin project engineering and permitting in the third quarter of 2018, and commence site work and

subscriber outreach in early 2019.

Each selected SCEF is required to post a development period security, equal to $20 per kW (AC) of

its proposed nameplate capacity, with the associated EDC. If a SCEF is not in-service within twelve

months after its guaranteed in-service date, and fails to meet certain additional requirements before the

end of that twelve-month period, the SCEF would be in default. A SCEF in default would no longer

be eligible for the tariff under the pilot program, and would forfeit the development period security.

F. Generation Technology and Distribution System Impact

Although the SCEF pilot program was open to all Class I renewable energy sources, project proposals

submitted in response to the Initial SCEF RFP were limited to two types of generating technology:

fuel cell (two project proposals) and solar photovoltaic (“PV”) (seventeen project proposals). With the

subsequent SCEF RFP, all nine projects proposals utilized solar PV technology.

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Of the nineteen project proposals generated by the Initial SCEF RFP, one fuel cell project and fifteen

solar PV projects were sited in Eversource territory, and one fuel cell project and two solar PV

projects in UI territory. Of the nine solar PV project proposals received in response to the SCEF RFP,

seven were located in Eversource territory and two were located in UI territory.

DEEP’s qualitative evaluation of the project proposals included consideration of the positive and

negative impacts that a proposed SCEF may have on the distribution system based on the location of

the facility. While not a requirement for program participation, inclusion of this factor encourages

mindful selection of sites more conducive to enhancing system integrity. To this end, both iterations of

the RFP provided prospective bidders access to maps previously developed, at the request of DEEP,

by the EDCs for informational purposes. In pertinent part, these maps emphasized locational

desirability for substations based on whether the substation was nearing its maximum capacity in each

EDC’s service territory, with the red substations as the “most desirable”, the yellow substations as

“desirable”, and the green or blue substations as the “least desirable”. The RFP cautioned that these

indicators do not necessarily mean that the cost or complexity of interconnections, or market pricing

will be less costly or complex than other locations.

As noted in the June 28, 2017 Final Determination, DEEP’s selection of the CHIP Fund 5 Riverside

Thompson project was, to some degree, because of the project’s close proximity to a substation

deemed “most desirable.”

G. Environmental and Land Use Impacts from Siting

A number of DEEP’s other recent RFPs, specifically RFPs issued pursuant to Public Act 15-107, have

elicited a growing discourse over environmental concerns regarding site optimization for state-

procured renewable projects. This led to several RFPs incorporating additional criteria to limit

potential impacts to environmental resources, including endangered species and wildlife habitat

protection, core forests, water quality and other considerations such as the protection of prime and

important farmland.

DEEP’s evaluation of project proposals submitted in response to the Initial SCEF RFP indicated that

many of those proposals called for clearing wooded land or locating the facility on prime farmland.

Therefore, in the subsequent SCEF RFP, DEEP provided new standards for environmental

considerations as a threshold requirement and as part of the qualitative evaluation, rather than solely

encouraging environmentally-based site optimization as a qualitative factor to be evaluated.

Specifically, as a threshold requirement, developers had to attest that the generation site of the SCEF

does not impact, in whole or in part, prime farmland, historic preservation property, or core forest.

Developers also needed to demonstrate that locating the SCEF at the generation site will not

significantly affect any endangered, threatened and special concern species and significant natural

communities based on the Natural Diversity Data Base. Qualitatively, the project proposals were

ranked more favorably for the positive re-use of sites with limited development opportunities, such as

brownfields and landfills.

11

The nine project proposals submitted in response to the SCEF RFP demonstrated that much more

effort was taken by developers to site their proposals in appropriate locations that limited land use

impacts. Three projects were located on landfills, one on a vacant municipal property that does not

require tree clearing, one on a brownfield and another on a former industrial site. The locations for the

remaining three projects were identified as edge forest requiring some clearing, but none are on core

forests or farmland. The locations of the three selected projects are as follows:

CHIP Fund 5 Thompson SCEF – an industrial site that housed a former mill;

CEC Bloomfield SCEF – vacant municipal property, no tree clearing; and

US Solar Shelton SCEF – former landfill site.

H. Consumer Protections, Subscription Documents, and Billing Terminology

Pursuant to the SCEF Act, DEEP established Consumer Protection Rules for subscribers and

potential subscribers under the SCEF pilot program. The Consumer Protection Rules provide

certain terms, disclosures, and other consumer protection provisions applicable to the

interactions and transactions by and between an SO or its agent, an EDC customer, and/or a

subscriber or prospective subscriber of a SCEF selected to participate in the pilot program. The

Consumer Protection Rules, which were appended to the SCEF RFP as Appendix C, may be

accessed via DEEP’s dedicated webpage for the SCEF pilot program, www.ct.gov/deep/SCEF.

DEEP’s qualitative evaluation of the project proposals allowed for consideration of the extent to

which a project proposal includes consumer protections beyond those mandated by the Consumer

Protection Rules. Of the project proposals submitted in response to the SCEF RFP, DEEP did not

identify any bidders that appreciably extended beyond what the Consumer Protection Rules already

stipulate. One bidder stated its commitment to adhering to best practice standards to protect consumer

privacy and data; however, Section 5 of the Consumer Protection Rules already outlines the

restrictions and the limited disclosures regarding a subscriber’s or prospective subscriber’s energy

usage or personally identifiable information. Moreover, each SO is already required to provide its

subscriber information privacy policy to its subscribers and prospective subscribers. Another bidder

indicated that it would make participation as effortless and streamlined as possible, which relates more

to quality of service. Yet another bidder pointed out that its SCEF program will not require credit

reports or security deposits, and will limit subscriber participation on a 60-day to 60-basis. However,

DEEP views this more as a novel program model approach worthy of implementation under the pilot

program for feasibility and potential future applicability, rather than as an enhancement to consumer

protections.

The SCEF RFP required each selected bidder to submit its subscriber agreement, subscriber

agreement summary form, any marketing materials, and its webpage content for approval by

DEEP prior to using such documents with prospective subscribers, for compliance with the

Consumer Protection Rules and the SCEP RFP. Since the June 28, 2017 Final Determination,

DEEP’s primary activity with the pilot program has centered on ensuring that such documents are in

compliance with the RFP and the Consumer Protection Rules (Appendix C of the SCEF RFP).

12

During the course of reviewing the SOs’ documents, DEEP viewed some variance in how the three

selected bidders separately framed their billing and credit structure under the pilot program. In

particular, the Consumer Protection Rules require the subscriber agreement to provide a plain

language disclosure of the subscription fee and the credit to be delivered to the subscriber. While the

SCEF RFP (and the Consumer Protection Rules, by extension) endeavored to include defined

terminology for the transaction components of the billing and credit structure, inconsistent use of

certain terms within the three subscriber agreements provided opportunity for further

misinterpretation, which may negatively affect the success of the pilot program. After some discussion

with the three bidders, DEEP recommended that the SOs use of the following terms and definitions

for the SCEF pilot program going forward to the extent these items are referenced in the subscriber

agreement, subscriber agreement summary form, marketing materials, and website content:

On-bill credit – the value of the subscribed energy allotment that is credited on the

subscriber’s EDC bill;

On-bill credit rate – the rate at which the on-bill credit is calculated (e.g., 17¢/kWh);

Subscription payment – the portion of the on-bill credit that the subscriber must pass

through to the subscriber organization;

Subscription payment rate – the rate at which the subscription payment is calculated (e.g.,

15¢/kWh);

Subscriber savings – the difference between the on-bill credit and the subscription

payment; and

Subscriber savings rate – the rate at which the subscriber savings are calculated (e.g.

2¢/kWh).

The use of the standard terms and definitions by all three SOs should improve the subscribers and

potential subscribers’ understanding of how the pilot program operates, and what their responsibilities

are in order to receive subscriber savings. Moreover, consistent use on a program-wide basis

eliminates SO-specific terminology, and ensures similar understanding by the personnel of other

entities that might be involved at some point (e.g., representatives of the EDCs when discussing

electricity bill payments, representatives of the PURA’s Consumer Affairs Unit when responding to

an inquiry, complaint or dispute about an SO). Accordingly, DEEP recommends continued use of

these terms for the forthcoming statewide SCEF program.

DEEP notes that Section 4.b of the Consumer Protection Rules requires the SOs to include an

approval designation given by DEEP in any information they use toward marketing or sales activities.

However, concurrent with its review of the SOs’ documents, DEEP was in the process of developing

a specific webpage for the SCEF pilot program. In addition to providing key details about the pilot

program, this webpage identifies and gives information about the three projects selected to participate

in the program. It also provides hyperlinks to the program-specific webpages created by the SOs and

approved by DEEP. Accordingly, in lieu of the approval designation, DEEP has required the SOs to

13

include the hyperlink to the SCEF pilot program webpage on their respective marketing materials and

web content.

To date, DEEP’s review of each SO’s set of documents has not fully concluded due to remaining

compliance issues that must be satisfied before active program use. The following table provides the

status of each SO’s subscriber-facing documents and web content, as of June 28, 2018:

Items

CHIP Fund 5

Thompson SCEF

Clean Energy Collective

Bloomfield SCEF

US Solar

Shelton SCEF

Advertising/marketing

materials

An introductory marketing

letter (for prospective

tenants who may be LMI)

was submitted; DEEP

provided feedback seeking

adjustments to meet RFP

compliance; DEEP awaits

CHIP Fund 5’s response

and re-submission

Sales rep badge template,

and CEC sales tool (PPT

presentation) are compliant

as of 6/19/2018; “leave

behind” data sheets

(residential and commercial

versions) are deemed

compliant as of 6/19/2018,

on the condition that they

are amended to incorporate

the required non-affiliation

statement

US Solar has re-submitted

its “CT SCEF Marketing”

flyer/handout in response to

initial DEEP feedback;

DEEP is currently

reviewing re-submission

for compliance

Website content A mock-up of a website

marketing page was

submitted; DEEP provided

feedback seeking

adjustments to meet RFP

compliance; DEEP awaits

CHIP Fund 5’s response

and re-submission

DEEP awaits CEC’s

submission of screenshots

of CT-specific webpages

US Solar has re-submitted

its website content in

response to initial DEEP

feedback; DEEP is

currently reviewing re-

submission for compliance

Subscriber agreement(s) A draft subscriber

agreement was submitted;

DEEP provided feedback

seeking adjustments to

meet RFP compliance;

DEEP awaits CHIP Fund

5’s response and re-

submission

Subscriber agreements

(residential, commercial,

and governmental versions)

are deemed compliant as of

6/19/2018

US Solar has re-submitted

its subscriber agreements in

response to initial DEEP

feedback; DEEP is

currently reviewing re-

submission for compliance

Subscriber agreement

summary form

A draft summary form was

submitted; DEEP provided

feedback seeking

adjustments to meet RFP

compliance; DEEP awaits

CHIP Fund 5’s response

and re-submission

Summary form is deemed

compliant as of 6/19/2018 US Solar has re-submitted

its summary form in

response to initial DEEP

feedback; DEEP is

currently reviewing re-

submission for compliance

Going forward in the statewide implementation of the SCEF program, DEEP will explore using

standardized documents that also provide sufficient flexibility to allow for constructive differences in

the SOs’ approaches, subject to approval by DEEP and PURA.

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I. Reporting Requirements to DEEP after Commercial Operation Commences

After commercial operation of a selected SCEF commences, each bidder is required to report certain

information to DEEP, initially within three months of that date and then annually thereafter:

Detailed information on all subscribers upon entering a subscriber agreement in the

preceding year, including each subscriber’s meter address, customer class, and historic

average annual electric use upon entering in the subscriber agreement; date of entry and

exit from the subscriber organization (if applicable); subscriber savings1 received; and

subscription method, including but not limited to the payments made for a subscription;

Household income information upon entering the subscriber agreement, or other form of

proof thereof, on all subscribers or a tenant of a master-metered multi-unit building

identified as LMI by the SO and how such subscribers were qualified as LMI in the

preceding year;

Detailed information on the termination fees charged or other damages collected from

subscribers for terminating the subscriber agreement in the preceding year, including but

not limited to the amount charged, the number of subscribers charged, how the fee was

collected, whether such subscribers were identified as LMI, the reason for termination of

the subscriber agreement, and the rate class of such subscribers;

All marketing materials used to solicit prospective subscribers in the preceding year,

including but not limited to the website used by the SO;

The number of subscriptions, and kWhs associated with any such subscriptions, that

were: (1) transferred to another subscriber, or to another location with the same

subscriber; (2) terminated; or (3) downsized in the preceding year; and

A sworn affidavit that the SO has complied with the LMI subscriber requirements

detailed in Section 3.8 of the SCEF RFP for each month in the preceding year.

DEEP looks to perform further evaluation of pilot program subscribership and administration, after

one or more of the three selected bidders have commenced operation of their SCEFs and begin to

submit reports on their actual pilot program experience. DEEP intends to review these compliance

reports to assess the performance of the pilot program to ensure that the SOs appropriately administer

their respective SCEF pilot programs and LMI qualification methods in conformance to the RFP and

the Consumer Protection Rules, and to gauge achievability of program objectives (i.e., expanding

clean energy deployment, increasing LMI access to clean energy, optimizing site selection, supporting

economic development, and minimizing electric ratepayers’ costs).

J. Identification and Analysis of the Success of Similar Programs in Other States

States across the nation offer variations of SCEF, or community solar, programs. Every program is

labeled something different and has different definitions, but the central objective is to offer a group of

customers a value on their electric bill for the generation of an offsite facility for which they subscribe.

1 The SCEF RFP, at page 33, originally used the term “Credit.” Refer to the above section, Consumer Protections,

for the current use of the term “Subscriber savings” in place of “Credit.”

15

Included in Appendix A is a more detailed overview of community solar programs in other states. The

majority of the programs are exclusively solar with only a few states that allow other renewable

technology. Of the 10 states discussed (see Appendix A), 8 of them offer programs through either net

metering or virtual net metering. Maine enacted legislation in 2017 to transition community solar into

a program that is separate from net metering. Currently, only Connecticut and North Carolina offer a

program that stands alone without net metering. The majority of states offer grants and incentives to

subscribing organizations to cover the costs of the facilities and can be in the form of direct payments

to the generator or long-term power purchase agreements.

In assessing programs across multiple states, DEEP identified the following key common factors:

Program size

Facility size

LMI requirements

Number of Participants

Subscription requirements

Treatment of excess generation

Valuation of benefits

Three states base the entire shared solar program size on a percentage of load for the utility.

Massachusetts allows up to six percent of the utility’s peak load for all net metering, with shared solar

authorized under this cap. Similarly, Delaware’s program is subject to a net metering cap of five

percent of electrical suppliers aggregated customer monthly peak demand. Other states are similar to

Connecticut and offer a MW limitation: Maine is authorized for 50 MW, Maryland at 300 MW, North

Carolina at 20 MW, New Hampshire at 100MW for all net metering, and Rhode Island at 30 MW.

Maryland’s program is also a three-year pilot with a 25-year term for the projects.

A shared solar facility can range from 100 kW up to 10 MW in size. Connecticut, New Hampshire

Massachusetts, Maryland and North Carolina allow facility between 1 MW and 5 MW. Rhode Island

allows up to 10 MW. Vermont allows much smaller facilities sized from 500 kW. Maine also requires

2 MW of the entire program capacity to be reserved for facilities with a net generating capacity less

than 100kW. Delaware breaks it down by residential, non-residential and farm customers with limits

on each from 25 kW to 2 MW.

LMI subscribers have set asides in Connecticut, Rhode Island and Maryland. Connecticut’s pilot

requires 20 percent to LMI. Maryland requires 60 MW be set aside for LMI. Rhode Island encourages

facilities to include LMI subscribers, but there are no set requirements. State programs that focus on

LMI subscribers often allow shorter subscription terms, little or no upfront costs for subscribers, and

verify LMI subscribers based on income compared to the area median income for the state or HUD.

The Maryland Strategic Energy Investment Fund has set $3.5 million for shared solar grant incentive

program in 2018 to absorb the risk associated with LMI subscriptions. The funding will be allocated

16

through a competitive process. Maryland offers a grant to developers if they can address two specific

issues within the LMI community, namely significant energy savings and shorter contract periods.

Each state permits a different number of subscribers, all requiring a minimum number of subscribers

typically with no maximum. Maine has a limit of ten customer metered accounts per generating

facility and requires that there be a legally enforceable shared ownership interest in the facility. Some

states allow a subscriber to sign up with more than one facility but limits the total subscription value to

a percentage of the annual usage, which ranges from 100 to 120 percent of the customer load. All

states allow for estimated annual usage for accounts with no history.

In general, all states allow the subscriber to receive a credit for a specific portion of the facility

generation. Some states, especially those states that tie the shared solar program into net metering,

provide for the subscriber credit at the full retail rate. Other states require the subscriber credit to be a

specific $/kWh and some allow the credit to vary but have set limits if the credit reaches a specific

value.

Most states offer direction for excess generation the subscriber receives from the facility. All states

require the excess credit to appear on the subscriber’s electric bill, but states vary in how that credit is

calculated. Vermont is clear that excess generation can be credited to the subscriber for up to 12

months then any unused credits revert to the utility. Maine has a similar policy stating that after 12

months the credits expire and there is no compensation for excess. Some states allow the credit to net

out kWh charges, while others require a dollar value or facility cents/kWh value like Connecticut.

IV. CONCLUSION

Designing a successful and cost-effective statewide shared solar program requires a clear means

to keep project costs down, minimize impacts on non-participants, and ensure the program meets

other policy goals. Therefore, DEEP recommends the following policy components be

incorporated into any statewide program, many of which have been incorporated into the Energy

Future Act:

Competition. Similar to the pilot program and other clean energy programs in

Connecticut, SCEFs should be required to participate in a competitive auction to drive

down the price of these resources, which may be tied to the Low and Zero Emissions

Renewable Energy Tariff auctions. This will allow these projects to compete alongside

similarly sized projects that serve commercial and industrial customers, municipalities,

state agencies, and agricultural customers.

Eligibility. To ensure meaningful customer participation, the statewide SCEF program

should require that all participating customers (with possible exemptions for LMI

customers and small businesses) purchase solar panels or a percentage of the facility

output and pay the full cost upfront, or enter into a long-term lease arrangement that

requires a fixed payment each month not tied to the actual monthly output of the facility.

This fixed payment would contribute to development of the clean energy system and

17

limit the rate impact on non-participant ratepayers. A lease arrangement could be

structured to provide a flat rate over the lease term. This would enable participants to

receive the value of owning a PV system (obtaining electric bill credits in return for their

support of the grid) without the burden of installation and maintenance. The EDC would

pay credits to the customer on a fixed cents/kWh basis for energy the facility produces.

These improvements would limit the rate impact on non-participating ratepayers for the

credits obtained by subscribers.

Exemptions for LMI customers and small businesses. DEEP recognizes that

leasing/ownership requirements would likely result in higher costs and other burdens for

participants. Many states intend their shared solar programs to specifically benefit LMI

customers who do not have rooftop solar access and cannot take advantage of

conventional net metering. Imposing high program participation requirements may work

against this accessibility goal. Ensuring high participation rates by LMI customers can be

a worthwhile goal in the context of reducing energy burden and meeting other policy

objectives. A program or projects specifically targeting LMI customers and/or small

business customers could be exempted from the leasing/ownership requirements through

the tariff structure.

DEEP looks forward to implementing the statewide program required by the Energy Future Act.

DEEP intends to use information, feedback, and lessons learned from its experience with the SCEF

pilot program in preparation for the opening of that proceeding by September 1, 2018.

APPENDIX A

A-1

State Program Size Facility Size Subscription Requirements

/ Size Number of Participants

LMI

Connecticut 6MW Up to 2MW ≥10 per facility 20% of estimated annual output

Delaware Subject to statewide net metering cap of 5% of Electric Supplier's aggregated customer monthly peak demand (utilities may increase limit)

Non-residential customers 2 MW - 500kW; municipal and residential customers to not exceed 25kW; farm customers not to exceed 100kW

Maine 60MW >25MW Up to 10 meters can be net metered against a single eligible facility.

Maryland 193MW statewide 2MW Not to exceed 200% of subscriber’s baseline usage

>1 60MW set aside for LMI grant program http://energy.maryland.gov/residential/Pages/CommunitySolarLMI-PPA.aspx

Massachusetts All net metering capped at 6% of utility's peak load (3% allocated to government-owned systems, 3% to non-government systems)

<1MW private facility; <10MW public facility

>2

New Hampshire All net metering capped at 100 MW

1MW Subscriber can sign with more than one facility but cannot exceed subscriber’s total load

>1 30 MW for LMI; Restricts occupancy of the housing to households with a gross annual income not exceeding 80% of the area median income as defined annually by US HUD; Restricts the monthly rent, including a utility allowance, that may be charged to residents, to an amount that does not exceed 30% of the gross monthly income of a household earning 80% of the area median income as defined annually by HUD. The value of the credits shall be used to provide a direct benefit to tenants of LMI housing.

A-2

State Program Size Facility Size Subscription Requirements

/ Size Number of Participants

LMI

North Carolina 20MW 5MW Minimum subscription size of 200 W. Subscription size cap is 100% of the maximum annual peak demand of electricity of each subscriber at the subscriber's premises.

>5

Rhode Island 30MW 10MW >3

Vermont The cumulative output capacity of net metering systems equals 4% to 15% of the distribution company’s peak demand during 1996; or the peak demand during the most recent full calendar year, whichever is greater.

500kW; 2.2MW military

A-3

State Treatment of Excess

Generation Net

Metering Valuation of Benefits Link

Connecticut Subscriber carries dollar value credit on bill for up to one year, EDC pays out any credit after 12 months

Each subscriber's monthly electric bill from the EDC will include an on-bill credit representing the value of the subscribed energy allotment

http://www.ct.gov/deep/cwp/view.asp?a=4405&Q=600224&deepNav_GID=2121

Delaware Annually subscriber can request payment from Electric Supplier, if less than $25 can be carried over on bill as credit

Yes For participants on the same distribution feeder as the Community Energy Facility, full retail rate. For customers not on the same distribution feeder, Standard offer service rate.

https://legis.delaware.gov/json/BillDetail/GetHtmlDocument?fileAttachmentId=38650

Maine Carried over as a kWh credit for 12 months expires after 1 year with no compensation

1:1 kWh credit http://legislature.maine.gov/legis/bills/getPDF.asp?paper=HP1120&item=1&snum=127

Maryland Electric bill credit only as either kWh or dollar value credit

Yes An electric company that does not provide Standard Offer Service shall pay a subscriber for kWh of excess generation at the electric company’s avoided cost of generation.

http://www.psc.state.md.us/electricity/community-solar-pilot-program/

Massachusetts Credits appear as a dollar value on bill and never expire

Yes Credit equal to the excess kilowatt-hours by time of use billing period, if applicable, multiplied by the sum of the distribution company's: (i) default service kilowatt-hour charge in the ISO-NE load zone where the customer is located; (ii) transmission kilowatt-hour charge; and (iii) transition kilowatt-hour charge; provided, however, that this shall not include the demand side management and renewable energy kilowatt-hour charges set forth in sections 19 and 20 of chapter 25.

https://malegislature.gov/Laws/SessionLaws/Acts/2008/Chapter169

New Hampshire Payment equal to utilities default service rate on an annual basis

Yes The customer-generator may elect to be paid or credited by the electric distribution utility for its excess generation at rates that are equal to the utility's avoided costs for energy and capacity to provide default service as determined by the commission consistent with the requirements of the Public Utilities Regulatory Policy Act of 1978.

http://www.gencourt.state.nh.us/rsa/html/XXXIV/362-A/362-A-9.htm

North Carolina Avoided cost The offering utility shall credit the subscribers to its community solar energy facility for all subscribed shares of energy generated by the facility at the avoided cost rate.

https://www.ncleg.net/Sessions/2017/Bills/House/PDF/H589v6.pdf

Rhode Island Yes Standard offer service kilowatt hour charge for the rate class applicable to the net metering customer, except that for remote public entity and multi-municipality collaborative net-metering systems that submit an application for an interconnection study on or after July 1, 2019 and community remote net-metering systems, the standard offer service kilowatt hour charge shall be net of the renewable energy standard charge or credit.

http://www.ripuc.org/eventsactions/docket/4631-NGrid-CNN-Presentation(1-11-17).pdf

A-4

State Treatment of Excess

Generation Net

Metering Valuation of Benefits Link

Vermont Excess credits rolled over to next month; after 1 year, any remaining credit reverts to the utility.

Yes The adder sum minus the residential rate per kWh charged by the company as of the date it files with the Board a proposed modification to its rate schedules to effect this subdivision (K) or to revise a credit previously instituted under this subdivision (K). The adder sum shall be $0.20 if the solar net metering system is of 15 kW capacity or less and otherwise shall be $0.19. The customer receives the credit for 10 years.

http://publicservice.vermont.gov/renewable_energy/net_metering